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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212J9991999-10-0101 October 1999 Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected ML20212L1831999-10-0101 October 1999 Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health ML20212L2081999-10-0101 October 1999 Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance ML20212L2171999-10-0101 October 1999 Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island ML20212L1971999-10-0101 October 1999 Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety ML20212K1241999-10-0101 October 1999 Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected ML20112E8911996-05-24024 May 1996 FOIA Request to Inspect & Copy Original OL Issued by Aec/Nrc for Util & EPP Issued as App B to Plant OL SNRC-2192, Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank1995-05-15015 May 1995 Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank ML20082B9131995-03-13013 March 1995 Submits Corrected Page for Insertion Into Final Rept Re Confirmatory Survey of RB & Phase 4 Systems at Plant ML20081A9321995-03-0707 March 1995 Forwards Final Rept Orise 95/B-81, Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6531995-03-0707 March 1995 Forwards Final Rept Orise 95/B-80, Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A6841995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Radwaste Bldg, Suppression Pool,Phase 2 & Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081B5801995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A7001995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 & Phase 3 Sys, Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A7111995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys,Shoreham Nuclear Power Station, Brookhaven,Ny SNRC-2189, Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 19941995-01-20020 January 1995 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 1994 SNRC-2188, Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey1995-01-20020 January 1995 Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey SNRC-2187, Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring1995-01-11011 January 1995 Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring SNRC-2182, Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning1994-11-0101 November 1994 Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning ML20077L3331994-10-25025 October 1994 Forwards Revised Proposed Confirmatory Survey Plan for Reactor Bldg Shoreham Nuclear Power Station Brookhaven,Ny ML20076K3881994-10-20020 October 1994 Forwards Proposed Confirmatory Survey Plan for Reactor Bldg, Shoreham Nuclear Power Station,Brookhaven,Ny,For Review & Comment ML20077M8351994-10-20020 October 1994 Forwards Draft Rept, Confirmatory Survey of Radwaste Bldg, Suppression Pool & Phase 2 Systems,Shoreham Nuclear Power Station,Brookhaven,Ny SNRC-2184, Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld1994-10-12012 October 1994 Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld SNRC-2185, Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-10-0404 October 1994 Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20076F9251994-09-26026 September 1994 Forwards Final Rept Orise 94/I-80, Confirmatory Survey of Turbine Bldg,Site Grounds & Site Exteriors Shoreham Nuclear Power Station Brookhaven,Ny SNRC-2183, Forwards Amend 6 to Indemnity Agreement B-871994-09-23023 September 1994 Forwards Amend 6 to Indemnity Agreement B-87 SNRC-2181, Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 11994-09-14014 September 1994 Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 1 SNRC-2180, Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-021994-09-0101 September 1994 Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-02 SNRC-2179, Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-09-0101 September 1994 Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl SNRC-2178, Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4))1994-08-17017 August 1994 Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4)) ML20072P1591994-08-17017 August 1994 Forwards Revised, Confirmatory Survey Plan for Radwaste Bldg & Suppression Pool for Plant SNRC-2176, Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-821994-08-0404 August 1994 Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-82 SNRC-2177, Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld1994-08-0404 August 1994 Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld ML20071L8741994-07-29029 July 1994 Forwards Confirmatory Survey Plan for Radwaste Building & Suppression Pool for Review & Comment SNRC-2175, Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively1994-07-18018 July 1994 Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively SNRC-2173, Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790)1994-06-14014 June 1994 Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790) SNRC-2172, Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-821994-06-0707 June 1994 Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-82 SNRC-2171, Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel1994-06-0202 June 1994 Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel SNRC-2170, Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan1994-05-20020 May 1994 Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan SNRC-2168, Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc1994-05-13013 May 1994 Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc SNRC-2169, Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project1994-05-11011 May 1994 Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project ML20029E1731994-05-11011 May 1994 Informs That Based on Recent Discussions Between Officials, Licensee Decided to Retain Organizational Position at Least Until Fuel Removed from Site ML20029D1991994-04-29029 April 1994 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program Annual Radiological Environ Operating Rept Jan-Dec 1993. ML20029D2571994-04-28028 April 1994 Advises That Jc Brons Resigned to Pursue Employment W/ Another Util Co,Effective 940429 ML20029C7111994-04-22022 April 1994 Submits Technical Info on Biological Shield Wall Blocks to Be Surveyed SNRC-2163, Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util1994-04-21021 April 1994 Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util ML20065M3701994-04-20020 April 1994 Responds to NRC Verbal Request for Info Re Estimated Cost for Decommissioning SNRC-2161, Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station1994-03-30030 March 1994 Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station SNRC-2160, Forwards Financial Info Required by 10CFR50.71(b)1994-03-30030 March 1994 Forwards Financial Info Required by 10CFR50.71(b) SNRC-2148, Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases1994-03-0808 March 1994 Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases 1999-10-01
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20112E8911996-05-24024 May 1996 FOIA Request to Inspect & Copy Original OL Issued by Aec/Nrc for Util & EPP Issued as App B to Plant OL SNRC-2192, Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank1995-05-15015 May 1995 Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank ML20082B9131995-03-13013 March 1995 Submits Corrected Page for Insertion Into Final Rept Re Confirmatory Survey of RB & Phase 4 Systems at Plant ML20081A9321995-03-0707 March 1995 Forwards Final Rept Orise 95/B-81, Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6531995-03-0707 March 1995 Forwards Final Rept Orise 95/B-80, Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081B5801995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6841995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Radwaste Bldg, Suppression Pool,Phase 2 & Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A7111995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys,Shoreham Nuclear Power Station, Brookhaven,Ny ML20081A7001995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 & Phase 3 Sys, Shoreham Nuclear Power Station,Brookhaven,Ny SNRC-2188, Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey1995-01-20020 January 1995 Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey SNRC-2189, Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 19941995-01-20020 January 1995 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 1994 SNRC-2187, Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring1995-01-11011 January 1995 Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring SNRC-2182, Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning1994-11-0101 November 1994 Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning ML20077L3331994-10-25025 October 1994 Forwards Revised Proposed Confirmatory Survey Plan for Reactor Bldg Shoreham Nuclear Power Station Brookhaven,Ny ML20077M8351994-10-20020 October 1994 Forwards Draft Rept, Confirmatory Survey of Radwaste Bldg, Suppression Pool & Phase 2 Systems,Shoreham Nuclear Power Station,Brookhaven,Ny ML20076K3881994-10-20020 October 1994 Forwards Proposed Confirmatory Survey Plan for Reactor Bldg, Shoreham Nuclear Power Station,Brookhaven,Ny,For Review & Comment SNRC-2184, Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld1994-10-12012 October 1994 Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld SNRC-2185, Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-10-0404 October 1994 Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20076F9251994-09-26026 September 1994 Forwards Final Rept Orise 94/I-80, Confirmatory Survey of Turbine Bldg,Site Grounds & Site Exteriors Shoreham Nuclear Power Station Brookhaven,Ny SNRC-2183, Forwards Amend 6 to Indemnity Agreement B-871994-09-23023 September 1994 Forwards Amend 6 to Indemnity Agreement B-87 SNRC-2181, Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 11994-09-14014 September 1994 Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 1 SNRC-2180, Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-021994-09-0101 September 1994 Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-02 SNRC-2179, Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-09-0101 September 1994 Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20072P1591994-08-17017 August 1994 Forwards Revised, Confirmatory Survey Plan for Radwaste Bldg & Suppression Pool for Plant SNRC-2178, Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4))1994-08-17017 August 1994 Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4)) SNRC-2176, Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-821994-08-0404 August 1994 Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-82 SNRC-2177, Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld1994-08-0404 August 1994 Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld ML20071L8741994-07-29029 July 1994 Forwards Confirmatory Survey Plan for Radwaste Building & Suppression Pool for Review & Comment SNRC-2175, Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively1994-07-18018 July 1994 Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively SNRC-2173, Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790)1994-06-14014 June 1994 Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790) SNRC-2172, Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-821994-06-0707 June 1994 Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-82 SNRC-2171, Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel1994-06-0202 June 1994 Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel SNRC-2170, Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan1994-05-20020 May 1994 Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan SNRC-2168, Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc1994-05-13013 May 1994 Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc SNRC-2169, Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project1994-05-11011 May 1994 Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project ML20029E1731994-05-11011 May 1994 Informs That Based on Recent Discussions Between Officials, Licensee Decided to Retain Organizational Position at Least Until Fuel Removed from Site ML20029D1991994-04-29029 April 1994 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program Annual Radiological Environ Operating Rept Jan-Dec 1993. ML20029D2571994-04-28028 April 1994 Advises That Jc Brons Resigned to Pursue Employment W/ Another Util Co,Effective 940429 ML20029C7111994-04-22022 April 1994 Submits Technical Info on Biological Shield Wall Blocks to Be Surveyed SNRC-2163, Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util1994-04-21021 April 1994 Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util ML20065M3701994-04-20020 April 1994 Responds to NRC Verbal Request for Info Re Estimated Cost for Decommissioning SNRC-2160, Forwards Financial Info Required by 10CFR50.71(b)1994-03-30030 March 1994 Forwards Financial Info Required by 10CFR50.71(b) SNRC-2161, Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station1994-03-30030 March 1994 Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station SNRC-2148, Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases1994-03-0808 March 1994 Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases SNRC-2145, Provides Comments Prepared by Util on Draft NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination1994-03-0808 March 1994 Provides Comments Prepared by Util on Draft NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination SNRC-2157, Forwards 1993 Rept of Personnel & Man-Rem by Work & Job Function. 1993 Personnel Exposures Extremely Low as Majority of Radioactivity Removed from Site1994-02-28028 February 1994 Forwards 1993 Rept of Personnel & Man-Rem by Work & Job Function. 1993 Personnel Exposures Extremely Low as Majority of Radioactivity Removed from Site SNRC-2158, Submits Notification of Pending Change to Decommissioning Plan Submitted 901229.Safety Evaluation for Change Encl1994-02-28028 February 1994 Submits Notification of Pending Change to Decommissioning Plan Submitted 901229.Safety Evaluation for Change Encl SNRC-2156, Forwards Annual Radioactive Effluent Release Rept for 1993. Latest Revised Copies of Offsite Dose Calculation Manual & Process Control Program Also Encl as Apps to Rept1994-02-25025 February 1994 Forwards Annual Radioactive Effluent Release Rept for 1993. Latest Revised Copies of Offsite Dose Calculation Manual & Process Control Program Also Encl as Apps to Rept ML20067C9271994-02-22022 February 1994 Forwards Fitness for Duty Program Performance Data for Period of Jul-Dec 1993 SNRC-2144, Forwards Vols 1-4 to Shoreham Decommissioning Project Termination Survey Final Rept. Twenty Proprietary Pages of Rept Withheld (Ref 10CFR2.790)1994-02-0404 February 1994 Forwards Vols 1-4 to Shoreham Decommissioning Project Termination Survey Final Rept. Twenty Proprietary Pages of Rept Withheld (Ref 10CFR2.790) 1996-05-24
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059L1841990-09-20020 September 1990 Informs of Promotion of Jg Wynne to Position of Facility Operations Div Manager,Effective 900827 SNRC-1753, Forwards Rev 5 to Security Training & Qualification Plan.Rev Withheld1990-09-18018 September 1990 Forwards Rev 5 to Security Training & Qualification Plan.Rev Withheld SNRC-1758, Informs That W Uhl Resigned from Util on 900831 & No Longer Needs to Maintain Senior Reactor Operator License 44311990-09-18018 September 1990 Informs That W Uhl Resigned from Util on 900831 & No Longer Needs to Maintain Senior Reactor Operator License 4431 SNRC-1755, Forwards Rev 5 to Safeguards Contingency Plan.Rev Withheld (Ref 10CFR73.21)1990-09-13013 September 1990 Forwards Rev 5 to Safeguards Contingency Plan.Rev Withheld (Ref 10CFR73.21) SNRC-1754, Requests That Annual License Fee for FY91 Be Held in Abeyance Pending Disposition of 900105 Amend Request1990-09-0707 September 1990 Requests That Annual License Fee for FY91 Be Held in Abeyance Pending Disposition of 900105 Amend Request SNRC-1752, Forwards Revised Tech Specs Re Defueled Status of Plant,Per Agreements Reached W/Nrc at 900802 Meeting1990-08-30030 August 1990 Forwards Revised Tech Specs Re Defueled Status of Plant,Per Agreements Reached W/Nrc at 900802 Meeting SNRC-1747, Forwards Semiannual Radioactive Release Rept for First & Second Quarters 1990 & Revised ODCM1990-08-23023 August 1990 Forwards Semiannual Radioactive Release Rept for First & Second Quarters 1990 & Revised ODCM ML20056B5041990-08-21021 August 1990 Forwards Application for Amend to License NPF-82,consisting of License Change Application 8,modifying Tech Specs by Deleting Independent Safety Engineering Group & Associated Controls SNRC-1750, Amends Util 900810 Request for Interim Relief from Tech Spec Limiting Condition for Operation 3.7.1.2.b.3 Associated W/ Plant Svc Water sys-shutdown.Requests That Relief Be Granted Starting 900817 & Ending 9009081990-08-15015 August 1990 Amends Util 900810 Request for Interim Relief from Tech Spec Limiting Condition for Operation 3.7.1.2.b.3 Associated W/ Plant Svc Water sys-shutdown.Requests That Relief Be Granted Starting 900817 & Ending 900908 PM-90-110, Forwards fitness-for-duty Program Performance Data for Jan-June 1990,per 10CFR26.71(d)1990-08-13013 August 1990 Forwards fitness-for-duty Program Performance Data for Jan-June 1990,per 10CFR26.71(d) SNRC-1744, Forwards Rev 1 to, Environ Qualification Rept for Class 1E Equipment for Shoreham Nuclear Power Station Unit 1 Lilco. Provides Technical Justification for Rev1990-08-10010 August 1990 Forwards Rev 1 to, Environ Qualification Rept for Class 1E Equipment for Shoreham Nuclear Power Station Unit 1 Lilco. Provides Technical Justification for Rev SNRC-1743, Advises That Util Eliminated Positions of Outage & Mod Div Manager & Outage Engineer.Safety Significance of Changes Evaluated.No Impact Exist Because Util Contractually Prohibited from Operating Facility1990-08-10010 August 1990 Advises That Util Eliminated Positions of Outage & Mod Div Manager & Outage Engineer.Safety Significance of Changes Evaluated.No Impact Exist Because Util Contractually Prohibited from Operating Facility SNRC-1746, Requests Interim Relief from Limiting Condition for Operation 3.7.1.2.b.3 Re Tech Spec for Plant Svc Water Sys - Shutdown1990-08-10010 August 1990 Requests Interim Relief from Limiting Condition for Operation 3.7.1.2.b.3 Re Tech Spec for Plant Svc Water Sys - Shutdown SNRC-1737, Forwards License Change Application 7 Requesting Amend to License NPF-82,conforming to Guidance of Generic Ltr 88-12 Re Fire Protection Requirements1990-07-20020 July 1990 Forwards License Change Application 7 Requesting Amend to License NPF-82,conforming to Guidance of Generic Ltr 88-12 Re Fire Protection Requirements SNRC-1732, Responds to Generic Ltr 90-03 Re Relaxation of NRC Position in Generic Ltr 83-28,Item 2.2,Part 2 Re Vendor Interface for safety-related Components1990-07-18018 July 1990 Responds to Generic Ltr 90-03 Re Relaxation of NRC Position in Generic Ltr 83-28,Item 2.2,Part 2 Re Vendor Interface for safety-related Components ML20044A9131990-07-0606 July 1990 Forwards Util Response to NRC Bulletin 90-001 Re Loss of fill-oil in Transmitters Mfg by Rosemount.No Model 1153 Series B Transmitters Installed at Plant SNRC-1735, Submits Organization Changes for WE Steiger & Jd Leonard Effective 9007091990-07-0303 July 1990 Submits Organization Changes for WE Steiger & Jd Leonard Effective 900709 SNRC-1733, Submits QC Div 1990 Staffing Rept,Per Sc Contention 13(d) Settlement Agreement.Actual Manhour Requirements for QC Under Projection Reported for Previous 2 Yrs1990-06-28028 June 1990 Submits QC Div 1990 Staffing Rept,Per Sc Contention 13(d) Settlement Agreement.Actual Manhour Requirements for QC Under Projection Reported for Previous 2 Yrs ML20044A3641990-06-28028 June 1990 Forwards Joint Application for Amend to License NPF-82, Designating Long Island Power Authority as Plant Licensee Upon or After NRC Amends License to Nonoperating Status ML20043F4741990-06-11011 June 1990 Requests Approval of Decommissioning Funding Method Set Forth in Encl Site Cooperation & Reimbursement Agreement Between Lilco & Long Island Power Authority ML20043D5761990-06-0505 June 1990 Requests Interim Relief from Action Requirements of Tech Specs 3.3.7.9,3.7.7.2,3.7.7.3 & 3.7.8 Re Establishing & Maintaining Continuous Fire Watches &/Or Hourly Fire Watch Patrols ML20043C3081990-05-30030 May 1990 Requests Interim Relief from Requirements of License Condition 2.C.(13),pending Dispostion of Util 891215 Request for Exemption from 10CFR50.54 & Amend to License.Condition Concerns Quarterly Emergency Plan Drills ML20043A9721990-05-18018 May 1990 Advises That,Effective 900501,LJ Calone & Ja Notaro Will No Longer Need to Maintain Senior Operator Licenses PM-90-072, Forwards Listed Lers,Updating Original Repts for Corrective Actions Deferred Due to State of Ny - Lilco Shoreham Settlement Agreement1990-05-16016 May 1990 Forwards Listed Lers,Updating Original Repts for Corrective Actions Deferred Due to State of Ny - Lilco Shoreham Settlement Agreement ML20042H0091990-05-14014 May 1990 Forwards Completed Questionnaire for Each Applicable Type of Operational Insp,Audit or Evaluation as Identified,Per Generic Ltr 90-01 ML20042E8241990-04-27027 April 1990 Responds to NRC Bulletin 90-002, Loss of Thermal Margin Caused by Channel Box Bow. Licensee Will Not Use Channel Boxes for Second Bundle Lifetime,Therefore,Bulletin Does Not Apply to Facility ML20042E2001990-04-17017 April 1990 Advises That H Carter,M Herlihy,J Reid,J Dunlap & a Burritt Resigned from Util & No Longer Need to Maintain Operator Licenses ML20012F0011990-04-0606 April 1990 Forwards Rev 19 to Security Plan.Rev Withheld (Ref 10CFR73.21) ML20012F5391990-04-0606 April 1990 Discusses Layup Implementation Program & Site Characterization Program for Plant.Util Intends to Remove Neutron Instrumentation & Other Selected Reactor Pressure Vessel Internals in Order to Obtain More Accurate Profile ML20012E2821990-03-28028 March 1990 Requests Interim Relief from Requirement That Util Conduct FEMA-graded Exercise of Util Offsite Emergency Response Plan by End of 1990 & That NRC-graded Exercise Be Deferred Pending Review of Proposed Defueled Emergency Plan ML20012E2771990-03-27027 March 1990 Forwards 1990 Internal Cash Flow Projection for Facility,Per 10CFR140.21 ML20012D2071990-03-22022 March 1990 Notifies That Listed Employees No Longer Need to Maintain Listed Senior Reactor & Reactor Operators Licenses ML20012C7781990-03-16016 March 1990 Requests Interim Relief from Certain Requirements Re Emergency Diesel Generators for Plant,Pending Disposition of Util Outstanding Request in 900105 Ltr to Amend License to Create Defueled Facility OL ML20012C6441990-03-15015 March 1990 Forwards 10CFR50.59 Rept for Jan-Dec 1989 & Discusses Rept Format.Title 10CFR50.59 Requires That Rept List Changes Which Did Not Involve Unreviewed Safety Question & Completed During Reporting Period ML20012C7571990-03-15015 March 1990 Forwards Request for limited-scope Exemption from fitness- for-duty Requirements of 10CFR26.Util Also Requests That Exemption Be Granted & Remain in Effect Until NRC Approves Final Disposition of OL ML20012C2271990-03-13013 March 1990 Requests Interim Relief from Primary Containment Leak Rate Testing Requirements of 10CFR50.54(o) & App J,III.D.1-3 Pending NRC Disposition of Lilco 891208 Request for Exemption from Same Requirements ML20012B5111990-03-0707 March 1990 Advises That F Sauerbrun No Longer Needs to Maintain NRC Senior Operator License 10602 Due to Resigning from Position on 900216 ML20012A9571990-02-27027 February 1990 Responds to Generic Ltr 89-19 Re Resolution of USI A-47 on Safety Implications of Control Sys & Generic Ltr 89-21.USIs A-45,A-46,A-47,A-48 & A-49 Completed.Status of USI A-47 Changed from Evaluating to No Changes Necessary ML20011F3841990-02-27027 February 1990 Forwards Semiannual Radioactive Effluent Release Rept,Third & Fourth Quarters of 1989. Rept Includes Info for Each Type of Solid Waste Shipped Offsite During Period & Meteorological & Dose Assessment Data for Entire Yr ML20006G1631990-02-27027 February 1990 Forwards Annual Ltr of Certification of Util Local Offsite Radiological Emergency Response Plan for Facility.Requests That Ltr Be Transmitted to FEMA for Review.Info Covers Emergency Equipment Inventory Sys & Training ML20006F4671990-02-20020 February 1990 Forwards Application for Amend to License NPF-82,revising Tech Specs to Conform to Generic Ltr 89-01, Implementation of Programmatic Controls for Radiological Effluent Tech Specs in Administrative Controls Section.... ML20006C2431990-01-31031 January 1990 Informs of Resignation of J Johnson & Expiration of Reactor Operator License 10480,effective on 900101 ML20011E0961990-01-30030 January 1990 Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Util Intends to Indefinitely Defer Implementation of Generic Ltr Recommendations & Requirements for Plant ML20005G9231990-01-22022 January 1990 Forwards Rev 4 to Security Training & Qualification Plan.Rev Withheld ML20006A2671990-01-18018 January 1990 Responds to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Action on Generic Ltr Deferred,Based on Defueled Condition of Reactor.Chlorination Sys Operated to Preclude Biofouling ML20005G2251990-01-12012 January 1990 Reaffirms Commitment Not to Place Nuclear Fuel Back Into Facility Reactor W/O Prior NRC Approval & Advises of Preliminary Steps Taken to Lower Ongoing Costs ML20005F8241990-01-0808 January 1990 Notifies of Termination of Employment of G Good & G Bobka as Licensed Reactor Operators ML20005F1631990-01-0505 January 1990 Forwards Application for Amend to License NPF-82,creating Defueled Facility Ol.Justification for Amend Provided in Encl Rept, Shoreman Nuclear Power Station Defueled Sar. ML20005E6021990-01-0505 January 1990 Forwards Rev to Physical Security Plan Re Fuel Storage in Spent Fuel Pool to Reflect Defueled Facility Ol.Rev Withheld (Ref 10CFR73.21(jj)) ML20005E8131990-01-0303 January 1990 Certifies That Util Developed & Is Implementing fitness- for-duty Program That Meets Requirements of 10CFR26.Program Provides Reasonable Measures for Detection of Persons Not Fit to Perform Activities within Scope of Commission Rules 1990-09-07
[Table view] |
Text
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- LONG ISLAND LIGHTING COMPANY
[ p~ g SHOREHAM NUCLEAR POWER STAMON k.a. eeN eie. NORTM eOUNTRY ROAe o WADeNe RlYsR N.Y.11Tret WILLIAM E. SYS9004. JR.
aansuwt vice me.. .,..veu.. ,,...,*"' SNRC-1658 N0y 1 0 1989 U.S. Nuclear Regulatory Commission l Document Control Desk Washington, D.C. 20555 l
-Attention: Dr. Thomas E. Furley, Director l Office of Nuclear Reactor Regulation ,
LILCO's Response to the September 15, 1989 Letter from NRC (T. Murley) to LILCO (W. Steiger, Jr.) !
Shoreham Nuclear Power Station - Unit 1 ;
Docket No. 50-322 ;
Refs (1) NRC (T. Murley) letter to LILCO (W. Steiger, Jr.) dated l September 15, 1989 ;
(2) Petition filed pursuant to 10CFR2.206 by J. McGranery, t Jr. on behalf of Shoreham-Wading River Central School !
' District and Scientists and Engineers for Secure Energy '
dated July 14, 1989 (SWR /SE 2 Petition)
(3) Supplement to SWR /SE 2 Petition dated July 19, 1989 -
(4) Supplement to SWR /SE 2 Petition dated July 21, 1989 j (5) Supplement to SWR /SE 2 Petition dated July 31, 1989 ,
(6) Petition filed pursuant to 10CFR2.206 by L. Bir;kwit, Jr. !
on behalf of Long Island Association dated August 4, i 1969 (L%A Petition) j
Dear Dr. Murley:
LILCO hereby presents its written response to your ?etter of i September 15, 1989 to me (Reference (1)) . ,
I. Introduction In Reference (1) , you instructed LILCO to review the petitions j filed pursuant to 10CFR2.206 by Mr. James P. McGranery, Jr., on behalf of the shoreham-Wading niver School District and Scientists and Engineers for Secure Energy, and by Loonard l' Bickwit, Jr., on behalf of the Long Island Association '
(collectively " Petitioners") and to address each concern raised therein. In Reference (1), you also briefly described the i various bases for the two petitions. In this response, LILCO has recharacterized slightly some of the stated bases of the two ,
AMI 8911150232 891110 i t PDR ADOCK 05000322 P PDC ,
I '
i SNRC-1658 c Page 2 petitions to reflect LILCO's own understanding of what Petitioners are arguing and to address more fully the concerns they are raising. Though several of the arguments being made in the two petitions are similar, for the sake of clarity, LILCO addresses each petition separately.
II. SWR /SE 2 Petition The SWR /SE 2 Petition consists of an initial request, dated July 14 l989, and three supplements, dated Ju'y 19, July 21, and July 31gj .
Because of the multiple supplex.ents to the petition, LILCO has found it difficult in rome instances to distinguish clearly between certain of the bases offered in support of the petition or to identify fully all of the allegations that are being made.
In this reponse, LILCO has attempted to characterize fairly the concerns that the petition raises.
A. Basis (1)
The first basis for the petition is that both the defueling of the Shoreham reactor and the storage of the fuel in the spent fuel pool, which the petition assumes to have been " conducted by the licensee pursuant to 10CFR50.59,* Reference (2) at 14, I involve an unreviewed safety question. Since LILCO has not
! obtained prior NRC approval to engage in these activities, the l petition argues, LILCO has violated 10CFR50.59. The petition l advances at least three separate arguments in support of this i claim.
t l First, the petition argues that LILCO has violated 10CfR50.59 l because the removal and storage of Shoreham's fuel is j
"unnecesrary," given that the fuel has not reached the end of its useful life, as is typically the case when such activities are conducted. The petition asserts that "(i)t is inherent in l the establishment of acceptable risks in (removing the fuel from the reactor), that there is a risk-benefit analysis taking as its premise the need to perform the activity." Reference (2) at 13 (emphasis in original). In the case of Shoreham, the petition argues, this supposed risk-benefit analysis does not apply. The July 31 supplement reiterates that the petition is not arguing that there is great risk in the defueling activity or in the storage of the fuel in the fuel pool per se, but that previous reviews of defueling activities have addressed the acceptability of that risk in light Reference (5) at 3.
l l 1/ By letter dated July 26, 1989, Mr. McGranery informed the NRC l that Scientists and Engineers for Secure Energy adopted and '
incorporated by reference as the bases for its petition the bases I
of the petition filed by the Shoreham-Wading River Central School l District.
L , . - _ _ _ _ J
P 'SWRC-1658 Page 3 of the benefit to be achieved
( h , either reloading of new fuel
. for continued operation or, in rare cases, mitigation of an accident) which is totally lacking here.
Second, the July 19 supplement argues that the storage of Shoreham's fuel in the fuel pool may reduce the " margin of I
safety' because 4 the public health and safety would no longer be protected by a combination of barriers provided by (a) the reactor vessel itself, (b) the primary containment and (c) the secondary containment, but would only be protected by the secondary I containment once the fuel is in the spent fuel pool.
j Reference (3) at 1-2. The July 31 supplement repeats this l assertion, arguing that the NRC should order LILCO to return the fuel to the reactor vessel i
i where the health and safety of the l
public will be protected not only by the secondary containment, but also by the primary containment and the reactor vessel itself ..s.
Reference (5) at 3.
Third, the July 31 supplement claims that at the meeting between LILCO management and the NRC Stafd on July 28, 1989, LILCO itself conceded that it had not completed the allegedly necessary safety analysis regarding transfer and storage of the fuel. Reference (5) at 2-3.
As a threshold matter, the petition has incorrectly assumed that the defueling of Shoreham and subsequent storage of the fuel in the fuel pool are activities that have been conducted pursuant to 10CFR50.59. As a result, the assertion that LILCO has violated 10CFR50.59 is entirely misplaced.
Section 50.59 (a) (1) provides that the holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, (ii) make changes in the
r .
'5WRC-1658 Page 4 procedures as described in the safety analysis report, and (iii) conduct tests or experiments not ,
?
described in the safety analysis report, without prior commission l approval, unless the proposed l change, test or experiment involves ;
a change in the technical bpecifications incorporated in the :
c license or'an unreviewed safety question. ,
What the petition overlooks is that the removal of the fuel from Shoreham's reactor is not a " change" in the facility, a " change" in the facility's procedures, or a " test or experiment" at all. <
To the contrary, the movement of fuel from the reactor vessel to the spent fuel pool, and the subsequent storage of the fuel in !
- the pool, is an activity typically associated with normal nuclear j plantoperationsandonethatispermjptedbyShoreham's '
technical specifications i%) REG-1357) . Accordingly, the provisions of 10CFR50.59 do not apply to LILCO's defueling i l activities.
Moreover, even if it is assumed, for the sake of argument, that ;
! the defueling of Shoreham is a " change" to the facility or to procedures within the meaning of 10CFR50.59, the petition fails '
to demonstrate that such change involves an "unreviewed safety question." The regulatory test for determining whether an f "unreviewed safety question" exists is provided in 10CFR50.59 (a) (2), which states that a e
proposed change, test, or -
experiment shall be deemed to i involve an unreviewed safety question (i) if the probability of '
occurrence or the consequences of '
an accident or malfunction of .
equipment important to safety previously evaluated in the safety analysis report may be increased; l 2/ In your' July 20, 1989, letter to Mr. McGranery, in which you 3enied the Shoreham-Wading River Central School District's 4 l
request that the NRC take immediate action to stop LILCO's '
activities at Shoreham, you stated that the "defueling of the i
I reactor vessel is an activity permissible under the terms of Facility Operating License NPF-82." See Letter from Thomas E.
Murley, Director of Nuclear Reactor Regulation, to James P.
McGranary, Jr., counsel for Shoreham-Wading River Central School l
District and Scientists and Engineers for Secure Energy at 2 l (July 20, 1989).
l 1
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[4 i
SNRC-1650 ;
', Page 5 }
1 or (ii) if a possibility for an accident or malfunction of a ,
different type than any evaluated previously in the safety analysis !
report may be created; or (iii) if ;
the margin of safety as defined in ;
the basis for any technical ]
specification is reduced.
Clearly, in advancing its " risk-benefit analysis" argument, the petition does not even begin to try to assess the defueling of r Shoreham against any of the three criteria specified in ,
10CFR50. 59 (a) (2 ) . LILCO has identified nothing in either the language of 10CFR50.59, the regulatory history of the provision, i or NRC case law to support the assertion that " inherent" in the l NRC's definition of "unreviewed safety question" is the "need" to perform the activity at issue.
In asserting that storage of the fuel in the fuel pool may reduce the " margin of safety," the July 19 and July 31 supplements come ,
closer to putting forth an arguement that attempts to assess i defueling against the standardb in 10CFR50.S9 (a) (2) . But the petition still fails to demonstrate that an "unreviewed safety -
question" is involved. The risks associated with the movement of fuel from the reactor vessel and the subsequent storage of the '
fuel in the fuel pool, outside the primary containment, have previously been analyzed in Section 15.1.36 of Shoreham's Updated l Safety Analysis Report.
Finally, it is simply not true that LILCO itself has conceded that at the time of defueling it had not completed the allegedly '
necessary 10CFR50.59 safety analysis. The then-uncompleted l
safety analysis to which LILCO personnel referred at the July 28 meeting with the Staff is an analysis that was being developed by .
LILCO's Nuclear F.ngineering Department to support certain license l Emendment and regulatory exemption requests that LILCO intends to l submit to the NRC in the future. See Transcript of Managenent 1
Level Meeting between the Nuclear Regulatory Commission and Long ,
Island Lighting company at 14 (July 28, 1989). LILCO was not l' required to complete and submit this analysis to the NRC prior to defueling Shoreham.
B. Basis (2)
The petition's second basis is an assertion that LILCO's reduction of staffing at Shoreham constitutes a " willful violation of the bases of the issuance of the license and the Reference (2) licensee's prior commitments to the Commission."
at 14. In particular, the petition refers to the staffing ,
information contained in the Operational Readiness Assessment Team (ORAT) report as evidence of LILCO's supposed " commitments" to the NRC with respect to staffiny at Shoreham. The July 31
, .. ,,..-.,.--,.,-.----,.,--..,.,_..._.-..,,.,.--__.,_-.__._.,,,.....,-,__,-_,,__-.,.w_,.,
s
supplement to the petition cites the then-pending transfer of Mr.
John D.. Leonard, Jr. from the Office of Nuclear Operations as further evidence of a need for the NRC to issue an immediately effective order to halt LILCO's staffing actions. Reference (5) ,
at 3-4.
LILCO does not know what the SWR /SE 2 Petition means when it claims that LILCO's destaffing activities constitute a
" violation" of the " bases of the issuance of" Shoreham's operating license. The ORAT Report did not create any commitments on LILCO's part to maintain a given level of staffing at Shoreham in all circumstances. As a licensee, LILCO must meet ,
the requirements imposed by applicable 11RC regulations and Shoreham's operating license. The Company is conmitted to meeting these requirements and has, in its view, done so. The Company is under no regulatory or licensing obligation, however, to maintain staffing at Shoreham at a level suitable to support power operations when, in fact, the plant is not being and will not be operated by LILCO.
Similarly, LILCO is under no obligation to keep Mr. Leonard as the head of Nuclear Operations. Mr. Leonard's successor is fully qualified to assume that position, a fact that the petition cannot and does not dispute.
C. Basis (3) '
[
l The third basis for the petition is the claim that the alleged I lack of certain maintenance activities at Shoreham " appear (e) to l be contrary" to the ORAT report. Reference (2) at 14-15. The
! July 31 supplement amplifies on this complaint by stating that (1) there is no " Operational Condition 6 in LILCO's Technical Specifications," and that (2) the Technical Specffications contain no definition of the terms " functional," *xecursd," and
" preserved," as used by LILCO to classify the level of Reference (5) at maingynanceofthevariousplantsystems.
4-5 Basis (3) is flawed in two principal respects. Firsta the petition has again misconstrued the significance of the ORAT l report. The ORAT report described the state of operational readiness at Shoreham at the time the inspection was conducted, -
3/ LILCO has since modified its classification program to use terms " operable," " functional," and " protected." LILCO has the previously described to the NRC Staff its plans for implementing its lay-up program. See letter from Anthony F. Earley, Jr.,
LILCO President, to Thomas E. Murley, Director of Nuclear Reactor Regulation (September 19, 1989).
~r - -- ., --- , _ . . . . _ _ . _
n s
SNRC-1658
,- Page 7
)
and' served to aid the Commission in determining whether to issue LILCO an operating license. The findings made by the NRC~ Staff ;
in the ORAT report did not themselves, however, impose on LILCO l' any requirement to perform some specified level of maintenance ,
<t above-that which is required by NRC regulations and the terms and
- conditions of LILCO's operating license. LILCO believes that it has met these requirements. Nothing in the petition demonstrates otherwise.
Second, as explained below, in complaining that LILCO is in violation of its license Pscause neither " Operational Condition 6" nor the. terms " functional," " secured," or " preserved" are '
defined in Shoreham's technical specifications, the petition misunderstands what the technical specifications require and tries to elevate form over substance.
l Under Shoreham's operating license, maintenance activities for various plant components and systems are described in the p " surveillance requirements" set forth in the plant's technical specifications . Failure to meet a given surveillance requirement is not, with few exceptions, a violation of the technical i
I specifications per so. Shoreham's technical specifications '
provide that (f)ailure to parform a Surveillance Requirement within the specified ,
l' time interval shall consitute a failure to meet the OPERABILITY L
requirements for a Limiting L Condition for Operation.
l Exceptions to these requirements
! are stated in the individual specifications. Surveillance l requirements do not have to be performed on inoperable equipment.
s NUREG-1357 at 3/4 0-2.
In other words, except for those specific surveillance requirements that must be performed at all times, failure to ,
perform maintenance on a given system as required by the applicable surveillance requirement merely renders that system
" inoperable" for purposes of plant operation. Once a system is rendered " inoperable," within a specified time period, either the system's " operability" must be restored or the specified " action" requirements must be met, up to and including plant shutdown. In order to resume operation after shutdown, the applicable surveillance must be performed and the sytem's " operability" reestablished. As long as the plant remains shut down, however, the technical specifications do not require that surveillance be performed on the " inoperable" system. LILCO's plans to cease
-surveillance of certain systems do not violate Shoreham's l
. ~ _ . _ _ - - - _ _ . - . - _ . _ _ _ . _ _ _ _ _ - -
I -16.
Basis (4) is predicated on a misreading of Apper dix B. Appendix B, 3.1 provides, in relevant part, that (b)efore engaging in additional construction or operational activities which may significantly affect the environment, the licensee shall prepare and record
i
.. 1
' .- (
l O s SNRC-1658
, Page 9 an environmental evaluation of each such activity. Activities are excluded from this requnrement if aTI measurable nonradiodovical effects are confined to the on-site 3reas previously disturbed during
~
site preparation and facility construction. When the evaluation indicates that'such activity involves an unreviewed
- environmental question, the
' licenses shall provide a written evaluation of such activity and obtain prior NRC approval.
NPF-82, Appendix B, 3.1 (emphasis added). As the highlighted portion above maker evident, prior NRC approval must be obtained only if the activity to be undertaken itself has some :
" measurable" environmental consequences offsite. Indeed, absent
.this threshold consideration, the licensee need not even prepare i a written evaluation of the activity.
l The petition does not contend, nor can it, that the actual activities.being addressed by the petition, e.g., the defueling i.
and destaffing of Shoreham, have any measurable offsite environmental consequences. Instead, the petition speculates that LILCO's decision not to operate Shoreham'will lead to a .
greater reliance on fossil fuel plants, and that this reliance will, in turn, result in a "significant increase" in a previously evaluated " adverse environmental impact." Yet the petition's speculation about the environmental consequencec of the substitution of fossil fuel plants for Shoreham is directed solely towards some possible future action. Such speculation does not demonstrate that LILCO's current activities in defueling the plant and transferring staff have any measurable offsite environmental consequences. Absent such a demonstration, the petition fails to establish that LILCO is in violation of NPF-82, Appendix B.
E. bases (5) and (6)$!
As best LILCO can determine, ac its fifth basis, the petition appears to be arguing that, under the National Environmental Policy Act (NEPA), a full environmental review must be conducted l before the NRC may permit LILCO to take any actions that may be directed towards (1) the transfer of Shoreham to the Long Island Power Authority (LIPA) or (2) the plant's eventual l
4/ LILCO does not perceive a clear distinction between bases (5) and (6) as the petition has characterized them. Accordingly, LILCO discusses both bases at the same time.
. _ .. ._. . _ . _ ~ . - . _ . . _ _ _ _ _ . _ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _
..- .SNRC-1658 ,
-Page 10 decommissioning. Reference (2) at 16. For its sixth basis, the ,
petition asserts that, by giving tacit approval to LILCO's defueling and destaffing activities at Shoreham, the NRC is violating its own NEPA-implementing regulations, which require that the NRC perform an environmental review before authorizing the decom Reference (2) l at16-18.gyssioningofanuclearpowerfacility. ,
The July.19 and July 21 supplements cite various newspaper articles that purport to describe the defueling and destaffing of Shoreham as being part of a " continuum of. actions" leading ,
towards decommissioning. The petition argues that this lands
. credence to its position that the !?RC's tacit approval of LILCO's activities violates NEPA. Reference (3) at 2; Reference (4) at 2-5. The July 31 supplement goes so far as to suggest that LILCO is engaging in a " stalling tactic" so as to allow the plant to ,
" decommission itself" and thereby presumably avoid prior environmental review. Reference (5) at 5-6.
Bases (5) and (6) of the SWR /SE 2 Petition are a challenge to NRC regulations. In implarenting the responsibilities imposed on it by NEPA, the NRC has determined through generic rulemaking that the appropriate time to begin the environmental review process for decommissioning is when the licensee submits, pursuant to 10CFR50.82, an application for a license amendment to terminate its license and decommission its facility. The NRC's NEPA-implementing regulations, as amended when the NRC revised its decommissioning regulations on June 27, 1988, establish that once such an application is made, the licensee is to bsgin the i
environmental review process by submitting a supplement to its prior environmental report. Specifically, these regulations provide that (e)ach applicant for a license amendment authorizing the 3ecommissioning of a production or utilization facility covered by 5/ The July 14 petition, citing 10CFR 51.20 (b) (5) , states that
( the decommissioning of a nuclear power plant necessarily requires l
the preparation of a site-specific environmental impact statement (EIS). Reference (1) at 16-17. This, of course, is incorrect.
l' When the NRC amended its decommissioning regulations last year, L
it removed subparagraph (b) (5) from 51.20 and eliminated the l requirement for a mandatory site-specific EIS for decommissioning. Under the NRC's current regulations, a site-specific EIS need be prepared only if the Staff's initial environmental assessment identifies impacts for a particular I
plant that are significantly different from those studied generically in the NRC's Final Generic Environmental Impact I Statement on Decommissioning of Nuclear Facilities (May 1988)
(NUREG-0586 ) . See Fed. Reg. 24039, 24052 (June 27, 1988).
l
e I '
[o SNRC-1658
'Page 11 i' 51.20 . . . shall submit with its application . . . a separate document, entitled " Supplement to Applicant's Environmental Report -
Post Operating License Stage,"
which will update " Applicant's Environmental Report - Operating License Stage," as appropriate, to reflect any new information or significant environmental change ,
associated with.the applicant's proposed decommissioning activities . . . .
10CFR51.53 (b) (emphasis added) . .
Once the applicant has submitted its supplement to the ,
environmental report, the responsibility for conducting the L environmental review shifts to the NRC Staff. Again, the NRC's regulations make it clear that-the Staff need not begin its review until the licensee's decommissioning amendment and environmental report supplement have been submitted.
Specifically, the regulations, as amended, state that l
(i)n connection with the amendment l of an operating license to authorize the decommissioning of a production or utilization facility covered by 51.20 . . . the NRC Staff will prepare a supplemental .
environmental impact statement for the post operating license stage or an environmental assessment, as appropriate, which will update the I
l prior environmental review.
10CFR51.95 (b) (emphasis added) .
The assertion that the NRC should begin its environmental review I of Shoreham's decommissioning before an application to terminate and decommission has been submitted is a challenge to the NRC's generic determination that the process neen not start until'such an application has been filed. One cannot use the 2.206 See, petition e.g, L process as a vehicle to challenge NRC regulations.
General Electric Co. (Vallecitos Nuclear Center, License No.
SNM-960), DD-79-9, 9 NRC 744, 753 (1979). For this reason alone,
> the allegations raised in bases (5) and (6) of the SWR /SE 2 Petition should be disregarded.
Nevertheless, in an effort to give fair treatment to the petition's concerns, bases (5) and (6) might be alternatively characterited as truly being not a challenge to the NRC's NEPA-I L
1 - - . . . - . _ - . - - . . . - - _ - . . - - . - - - , - -. - .- - -
s .
t SNRC-1658 7
., Page 12 implementing regulations, but as a complaint that LILCO is avoiding the formal requirements of the NRC's decommissioning -
regulations by engaging in a pattern of activities constituting "de facto" decommissioning. Even when characterized in this fashion, however, bases (5) and (6) lack merit.
LILCO is not engaging in de facto decommissioning because, while LILCO cannot and will never operate Shoreham, none of the actions that LILCO has taken so far with respect to Shoreham are '
inconsistent with the future operation of the plant by some '
entity other than LILCO. As LILCO has already explained to the NRC Staff, those systems at Shoreham that are not required for '
safety in the plant's present defueled mode will be kept in a
" protected" or layed-up mode. Thus, the steps that LILCO is currently taking with respect to Shoreham ensure that the plant will not " decommission itself" pending transfer of the plant to some entity of New York State.
III. LIA Petition The LIA Petition consists of a single document, dated August 4, 1989. As best LILCO can discern, four separate bases for the LIA Petition have been advanced. LILCO addresses each in turn.
t A. Basis (1)
The first basis of the petition is an argument that certain actions taken by LILCO with respect to Shoreham are in violation L of 10CFR50.59. The petition asserts that (c)utting staff, disregarding Commission upgrade orders, reducing maintenance and surveillance, and
[ deactivating procedures -- all of l which are part of the " minimum l
) posture condition" at Shereham --
l will undoubtedly increase the risks of accident or malfunction that would be associated with operating i
the plant as contemplated by the i license and raise safety issues l
that have not been "previously :
evaluated." l Reference (6) at 6-7. Arguing that LILCO cannot " elude the l requirements of 50.59 on the ground that no violation of the licensee's technical specifications has yet occurred," the petition asserts that "a violacion (of 50.59) has occurred" and that LILCO "should be made to comply with the requirements of 50.59." Reference (6) at 8. The petition goes on to argue that "even if the Commission is not prepared to make such a finding, it should institute an investigation into the issue." Reference (6) at 8.
e SNRC-1658
- Pcga 13
.The argument that LILCO has violated 10CFR50.59 does not differ in any material way from similar allegations made in the SWR /SE 2 Petition. LILCO has already explained why its approach to
? Shoreham is permissible under the terms of its license and why the requirements of 10CFR50.59 do not apply to movement of fuel ,
l from the reactor to tha spent fuel storage pool and the fuel's
?
, storage therein.
As for the petition's alternative suggestion that the NRC should institute an investigation, it is important to remember that the NRC Staff has met with LILCO on three occasions, each publicly noticed, to discuss Shoreham's status. In addition, through cor-respondence, LILCO has sought to keep the NRC fully apprised of.
every significant action the Company has taken with respect to :
the plant since the Settlement Agreement want into effect. The '
NRC Resident Inspector >at Shoreham has also been kept informed of LILCO's activities. Finally, the NRC Staff conducted a one-week
. inspection of LILCO's activities at Shoreham on September 18-22, 1989. At the conclusion of that inspection LILCO was told by the Staff that the company's actions with respect to Shoreham appear-ed to be reasonable. In short, the Staff has.already conducted thn sort of investigation that the petition has requested.
B. Basis (2)
As its second basis, the petition argues that "New York State authoriti,es, through the settlement agreement, have assumed un- l authorized control over the Shoreham license" in violation of the i Atomic Energy Act and NRC regulations. Reference (6) at 9. !
Given this alleged State control over LILCO's conduct of activi- 1 ties at Shoreham, the petition suggests that "even if LILCO were j to determine that public safety or plant maintenance consider-ations require an expenditure of funds, that determination 7ay be ' !
effectively overruled by the state." Reference (6) at 12.6 6/ While not advanced as a reparate basis, the July 19 i supplement to the SWR /SE 2 Petition also appears to allege that New York State is exercising impermissible control over LILCO's l activities with respect to Shoreham. The July 19 supplement l argues that the NRC Staff should order LILCO to cease and desist i and return to the status guo ante so that the NRC may determine l whether the economic objectives of the New York State Public Service Commission and the Licensee are consistent with the responsibilities accepted pursuant to the full power operating license, or whether the New York State Public Service Commission is subjecting the Licensee to unlawful '
economic pressures that would cause violations of the commitments the Licensee has made in obtaining its license.
Reference (3) at 4.
y L.. n SNRC-1658 F Page 14 h
1' LILCO has not surrendered control over Shoreham to New York
~
i State. As LILCO.has repeatedly stated to the NRC, as long as LILCO is the licensee of Shoreham, LILCO fully intends to abide y
- by all of the terms and conditions of that license and all i
pertinent NRC regulations. It is true that under the settlement-
!: Agreement, LILCO is obligated not to operate Shoreham and to E cooperate with New York State in obtaining NRC permission to ,
transfer the plant to an entity of the State. 'In all matters 1
-concerning regulatory compliance and conduct of plant activities under the license, however, LILCO continues to exercise its own -
' independent judgment. While LILCO forosees no c.)nflict between its obligations under the Settlement Agreement and its duty as an NRC licenses to protect the public health and safety and
.otherwise comply with NRC regulations and the terms of its license, should-any such conflict arise, LILCO intends to do whatever is required of it'to meet its NRC obligations.
I l
L C. Basis (3) 1 The' third basis of the LIA petition is an assertion that a >
"de. facto. decommissioning" of Shoreham is taking place.
! Reference (6) at 12-13. t As has been explained above, LILCO is not engaging in de facto decommissioning. Those systems at Shoreham that, under the plant's technical specifications, need not be kept in an
" operable" status with Shoreham in its defueled condition will be protected from degradation through a lay-up program. Those systems will be maintained in this " protected" condition pending Shoreham's transfer to an entity of New York State.
D. Basis (4)_
Finally, as its fourth basis, the petition argues that to prevent a "frustratien" of NEPA's purposes, the NRC must halt LILCO's activities at Shoreham, pending an environmental review.
Reference (6) at 16. The petition adds that the NRC cannot escape its NEPA responsibilities by claiming that its environmental obligations are not triggered until the filing of a formal decommissioning application.
Reference (6) at 13 As with the SRW/SE 2 Petition, the argument that the NRC must undertake an environmental review now, prior to the filing of an application to terminate Shoreham's license and decommission the plant, is a challenge to NRC regulations that may not be brought in the guise of a 10CFR2.206 enforcement proceeding.
( ,3 '-
C ,
SNRC-1658 !
Page 15 s
IV. Conclusion The requests made in the SWR /SE 2 and LIA Petitions that the NRC L issue an order to-LILCO to cease and desist its activities at L Shoreham and return to the status guo ante should be denied. As the information presented above demonstrates, the actions that LILCO has taken with respect to Shoreham are consistent with both ,
the plant's operating license and NRC regulat. ions.
Very truly yours, L 7
/ ,
l W. E. Steige ,
l Assistant Vice President Nuclear Operations DRH/ap cc S. Brown !
W. T. Russell F. Crescenzo i
e
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1 -
-t 852 COUNTY OF SUFFOLK )
b
'I, WILLIAM E. STElGER, JR., being duly sworn, depose and say that I am the Assistant Vice President - Nuclear Operations for the Long Island Lighting Company. I am authorized on the part of said Company to sign'and file with the U.S. Nuclear Regulatory
. Commission the enclosed letter (SNRC-1658) for the Shoreham Nuclear Power Station. This response was prepared under my supervision and direction; and the statements contained therein are true and correct to the best of my knowledge, information and belief..
.,4/A$nf k1 f
I William E.&Steiger, JA.
4 Sworn to before me this
/0 W day of MuteglA 1989 J
' ! T4 L
WKilAM J. HAGGERTY" !
Nagory Putdic, State of New York No.4712115 Quellfledin suffook county jc)g Commlesion Empiree July 31, l s i
'l 4 J